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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Employee DBS Reporting Policy

1. Purpose

The purpose of this policy is to ensure that all employees of {{org_field_name}} undergo and maintain appropriate Disclosure and Barring Service (DBS) checks as required under the Regulation and Inspection of Social Care (Wales) Act 2016 (RISCA) and CIW regulations. This policy sets out how we manage DBS checks efficiently, ensuring that all employees are suitable to work in a domiciliary care setting and that any changes in their criminal records or circumstances are promptly reported and addressed.

DBS checks are critical for protecting service users, staff, and the integrity of our organisation, ensuring that no employee poses a risk to vulnerable individuals. This policy also aligns with Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13) and the Fit and Proper Persons: Employed Staff Policy (DCW02) to maintain the highest standards of safety, ethics, and legal compliance.

2. Scope

This policy applies to:

• All employees, including care workers, managers, and office staff.
• Agency workers, volunteers, and contractors who have direct or indirect contact with service users.
• New applicants and existing staff who are required to renew their DBS certificates.

It covers:

• The process for obtaining and renewing DBS checks.
• Employee responsibilities for reporting DBS changes.
• Management of DBS disclosures, including risk assessments and escalation procedures.
• CIW reporting obligations.

This policy ensures that any criminal convictions, cautions, or police investigations that may impact an employee’s role are identified, assessed, and managed in accordance with safeguarding laws.

3. DBS Check Requirements

All employees working for {{org_field_name}} must undergo an Enhanced DBS check with Adult Workforce and Barred List checks before starting employment. DBS requirements are as follows:

• New Employees:
  • Must provide a valid Enhanced DBS Certificate issued within the last six months or be registered with the DBS Update Service.
  • Cannot commence work until a satisfactory DBS check has been received and verified.
  • Conditional employment may be offered only if supervised at all times until DBS clearance is confirmed.
• Existing Employees:
  • Must maintain a valid DBS certificate at all times.
  • Must renew their DBS every three years unless registered on the DBS Update Service.
  • Must immediately report any new convictions, cautions, arrests, or police investigations that could affect their suitability to work in care.
• Agency and Temporary Workers:
  • Must provide valid DBS clearance before being assigned to any service user.
  • If supplied via an agency, the agency must provide DBS verification in writing.

4. Employee Responsibilities for Reporting DBS Changes

All employees have a legal duty to report any changes to their DBS status that may affect their employment. These include:

• New convictions or cautions for any offence (including minor offences).
• Ongoing police investigations or pending charges.
• Involvement in any safeguarding concerns or referrals.
• Being placed on the Adult or Child Barred List.

Employees must report any of the above immediately to their line manager or the Registered Manager. Failure to disclose this information may result in disciplinary action, suspension, or dismissal.

If an employee is unsure whether a change in their circumstances needs to be reported, they should seek advice from the Registered Manager or HR.

5. How We Manage DBS Disclosures Efficiently

To ensure compliance with CIW regulations, {{org_field_name}} follows a structured and efficient approach in managing DBS disclosures:

• DBS Update Service: Employees are encouraged to register for the DBS Update Service, which allows for continuous monitoring and quick renewal. This reduces the need for repeated paper-based DBS applications.
• Annual DBS Status Check: For employees on the DBS Update Service, their status is checked annually to confirm continued compliance.
• HR DBS Tracking System: HR maintains a secure and up-to-date database of all DBS renewal dates, flagged three months before expiration to ensure timely renewal.
• Confidential Handling of DBS Disclosures: All DBS information is processed in line with GDPR and data protection laws. Only authorised personnel have access to this information.
• Escalation and Risk Assessment Procedures: If a DBS check returns information of concern, a formal risk assessment is conducted by the Registered Manager, determining whether:
  • The employee can continue working with additional supervision.
  • The employee should be suspended pending further investigation.
  • The case must be reported to CIW and the Local Authority Safeguarding Team.

6. Reporting to CIW and Safeguarding Authorities

{{org_field_name}} has a duty to report serious DBS concerns to CIW and relevant safeguarding bodies. Situations that require immediate reporting include:

• If an employee is placed on the Barred List.
• If a serious safeguarding allegation is made against an employee.
• If a DBS check reveals serious offences that were not previously disclosed.
• If an employee fails to report a conviction that could impact their role.

In such cases, the Registered Manager will:

• Suspend the employee if necessary, pending further investigation.
• Conduct an internal risk assessment to determine next steps.
• Notify CIW, the Local Authority, and, if required, the police or DBS service.
• Support affected service users to ensure their safety and well-being.

7. Disciplinary Action for Non-Compliance

Failure to comply with DBS reporting obligations will be treated as gross misconduct and may result in:

• Immediate suspension or dismissal.
• Referral to safeguarding authorities.
• Reporting to CIW for regulatory intervention.

Each case will be reviewed individually, and disciplinary decisions will be made in line with the Disciplinary and Grievance Policy (DCW31) and safeguarding regulations.

8. Employee Support and Training

To ensure staff understand their DBS responsibilities, {{org_field_name}} provides:

• DBS awareness training during induction and refresher training.
• Guidance on how to report DBS concerns safely and confidentially.
• Support for staff undergoing DBS investigations, including legal advice and counselling referrals where appropriate.

Staff are encouraged to ask questions and seek advice from the Registered Manager or HR if they have any concerns about their DBS obligations.

9. Related Policies

This policy should be read in conjunction with:

• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13)
• Fit and Proper Persons: Employed Staff Policy (DCW02)
• Staff Conduct and Code of Ethics Policy (DCW28)
• Disciplinary and Grievance Policy (DCW31)
• Confidentiality and Data Protection Policy (DCW34)

10. Policy Review

This policy will be reviewed annually or sooner if legislation, CIW guidance, or business needs change. Any updates will be communicated to all staff to ensure ongoing compliance.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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